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2. The facility is located on OMLLC private surface. The methane gas resource obtained <br />from the mine in -seam drainage system is a combination of fee and Federal gas resources. The <br />lease for the Federal gas resource is held by OMLLC sister company Gunnison Energy <br />Corporation (GEC). OMLLC and Vessels Coal Gas jointly own the fee gas. The facility will <br />enable the beneficial, economic use of the methane for non -mine related purposes. The OMLLC <br />Elk Creek Mine is only entitled to use the mine methane for mine related purposes. The use of <br />the methane for non - mining related purposes, as anticipated by this facility, will primarily utilize <br />the GEC gas resource. To avoid possible confusion as to the status of the methane borehole, a <br />COGCC permit will also be obtained. The permitting process for obtaining this COGCC Permit <br />have been initiated and a copy of the final permit will be forwarded to the Division as soon as it <br />is obtained. In effect the borehole will be covered by two Colorado regulatory jurisdictions, <br />CDRMS and COGCC. <br />3. Rule 2.03.10 requires the identification of other licenses and permits needed by the <br />applicant to conduct the proposed surface or underground mining activities. As this methane <br />facility is not a surface coal mining operation nor is it needed to conduct the mining activities, <br />Rule 2.03.10 does not apply. Nevertheless, we will be pleased to included reference to the <br />COGCC Permit number on PAP Page 2.05 -23C describing the facility. <br />4. Rule 2.05.3(3)(a) and Rule 4.05.18 uniquely apply to surface coal mining activities. We <br />are not aware that the concept of a SMCRA "stream buffer zone" otherwise applies to the <br />universe of non -coal mining activities. Nevertheless, while the facility will be located within the <br />mine's present 100 foot stream buffer zone area it will not encroach into the stream itself. The <br />outslope of the pad will be protected with rock salvaged during construction and the facility will <br />use small sediment traps, straw bale and straw waddle check dams, and rock surface drains to <br />minimize sediment to Elk Creek. It appears the Division has two possible options. The Division <br />may choose to 1) either leave the present buffer zone as is while acknowledging the existence of <br />a non - mining facility or 2) authorize a change in the location of the applicable buffer zone if it <br />believes a change in the findings are necessary. <br />5. See our comment #1 above. In addition, the facility will be located and accessed via the <br />currently approved post mining access road that will remain to access the upper reaches of Elk <br />Creek. <br />6. The proposed relocated alluvial monitoring well EC-14 location is shown on Maps 2.05 - <br />M1 and 2.05 -M4. The revised text for Exhibit 2.05 -E7, page 3 was provided in the application. <br />OMLLC proposes no changes in the monitoring schedule, completion, sealing, reclamation, etc. <br />of the alluvial well. The final well completion diagram will be forwarded to the Division for <br />inclusion in Exhibit 2.04 -E4, Item 3 after completion. We have attached a copy of the present <br />EC -14 well schematic for the Division's information. With the possible exception of a different <br />total well depth, we anticipate a similar completion for the relocated monitor well. <br />• Page 2 <br />